The U.S. Court of Appeals for the Sixth Circuit recently upheld a district court ruling that a long-term disability plan could bar a claim that exceeded its contractual limitation period. In this case, the plaintiff left employment with his employer in 2001 due to a variety of medical conditions. The plaintiff applied for and was denied long-term disability benefits because the claims administrator determined that nothing in the plaintiff’s file suggested that he had been “continuously disabled.” The plaintiff twice unsuccessfully appealed this benefit denial. In 2007, the plaintiff returned to work for his former employer, but after a year the plaintiff again left employment due to his medical conditions. Again he filed a claim for benefits under the long-term disability plan. This time his claim for benefits was successful. The claim administrator determined that his disability benefit would begin after he terminated employment in 2008. The plaintiff, however, sued the plan, arguing his disability benefit should have begun following his first termination of employment in 2001. The court upheld a district court ruling that the plan’s contractual provision, requiring participants to file an ERISA claim within three years, barred the plaintiff’s lawsuit. This case serves as a reminder that, to help protect the plan from liability, plan sponsors should include a contractual limitation period in their plan document. (Engleson v. UNUM Life Insurance Co. of America, 6th Cir., 2013)